Many things are happening around here as I work on this book I hope a few people will read. Myduck, who Karen saved by cracking open an abandoned egg, seems to be thriving. See http://holesinmyjeans-kpannabecker.blogspot.com/ for a charming video of the little guy and his mama. Replacement fences are rising in the barnyard. Our water heater is dying, as indicated by leaks at the top, so Karen's tracking down an on-demand replacement. We think a neighbor cat stole two of Ginger's other four ducklings last night. Oats are ready to be harvested, winter wheat to be gleaned, beets to be pickled and frozen.
I find myself fretting effective dates. The financial reform bill has so many it's mind-boggling. Effective dates may sound like a simple thing, but time and time again I discover they complicate bill and regulation analysis. This bill has a general section that says a provision takes effect the day after enactment unless some other section states otherwise. So, if President Obama signs the thing Wednesday as scheduled, the date of enactment is July 21, 2010 and the day after is July 22, 2010.
Title XIV (see, Roman numerals remain in vogue), one of 16 titles, includes a section that says its provisions take effect after regulations are adopted, on the date specified in the regulations -- unless another section of Title XIV states otherwise or regulations are not adopted by 18 months after the "designated transfer date."
Virginia asks, "What's the designated transfer date?"
Good question. By the 60th day after the date of enactment, which will be 60 days after July 21 -- now count with me to September 19 -- the Federal agencies need to get together and agree on the date on which the new Bureau of Consumer Financial Protection will assume its responsibilities. That date, which cannot be earlier than January 17, 2011 or later than July 21, 2011 (unless something unexpected happens) is the "designated transfer date."
"Enough," says Virginia. "I get the picture."
It's not that effective dates are hard to figure out. They're just difficult to keep straight.
Well, sometimes they are hard to figure out. Some of us are already disputing what that provision in Title XIV really means. I think I've got the best argument, but a court may have to settle it if Congress doesn't amend the thing.
Silliness. I'd rather be kayaking.
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